SUBRECIPIENT MONITORING
POLICY

ORIGINATOR: Business and Finance

DATE: May, 2003 (revised)

POLICY #99-1

I. PURPOSE

Federal regulations require pass-through entities to
monitor subrecipients. The purpose of this policy is to provide
guidance to University staff in monitoring subrecipients to ensure
their compliance with federal laws and regulations.

II. DEFINITIONS

PASS-THROUGH ENTITY: An OMB Circular A-133
term for a nonfederal entity that provides a federal award to a
subrecipient to carry out a federal program.

SUBRECIPIENT: A subrecipient is defined by OMB Circular
A-133 as a Non-federal entity that expends federal awards received
from a pass-through entity to carry out a Federal program, but does
not include an individual that is a beneficiary of such a program. A
subrecipient may also be a recipient of other federal awards directly
from a federal awarding agency.

RECIPIENT: A recipient means a
non-Federal entity that expends federal awards received directly from
a federal awarding agency to carry out a federal program.

III. APPLICABILITY

This policy applies to subrecipients of the
University of Rhode Island as distinct from vendors of the University
of Rhode Island.

A subrecipient is characterized as an entity that

Meets the objectives of the federal program through
performance measures.

Makes programmatic decisions.

Complies with applicable federal program requirements.

Uses the federal funds awarded to carry out a portion of the
program.

A vendor is characterized as an entity that

Provides goods and services as part of their normal business
operations to a pass-through entity.

Provides similar goods and services to many different
purchasers.

Provides goods and services that support the operation of the
federal program.

Operates in a competitive environment.

Is not subject to the applicable federal program requirements.

IV. MONITORING REQUIREMENTS AND
PROCEDURES

Whenever a subrecipient relationship exists, the
University at the primary recipient must monitor the subrecipient to
ensure its compliance with federal laws and regulations. The
monitoring responsibilities at the University are as follows:

A. The Research Office's responsibilities for subrecipient
monitoring shall include the following:

To review grant applications to ensure subrecipient agreements
were approved by the grantor agency.

To ensure each subrecipient agreement contains the condition
that the subrecipient complies with the federal requirements set
by the original grantor agency.

To ensure that the subrecipient agreement identifies the
federal program along with the CFDA number, and that the
University (or its auditor) has access to the subrecipient's
records.

To provide principal investigators with a copy of the
University's subrecipient monitoring policy and to advise them of
their responsibilities under this policy.

To monitor the activities of the subrecipient as necessary to
ensure that the federal awards are used for authorized purposes in
compliance with laws, regulations, and the provisions of the
contract or agreements.

To oversee the satisfactory performance of the contract to
ensure that goals are achieved.

To review and approve expenditures to ensure allowability.

C. The Office of the Controller, in compliance with Circular
A-133, and to establish controls in relation to the University's
subrecipient's expenditures, will perform the following monitoring
requirements:

Review invoices to ensure they are accurate and approved for
payment by the principal investigator.

Review expenditures for compliance with applicable laws,
regulations, and contract/agreement provisions, as management
deems necessary during the approval process.

Review subrecipient account to ensure that actual expenditures
and commitments do not exceed the approved budget.

Ensure that subrecipients expending $300,000 or more in
Federal Awards during the subrecipient's fiscal year have met the
audit requirements of this part for that fiscal year by requesting
A-133 certifications as necessary.